Version: 1.4

Date: May 13, 2020

Prepared for: USDA OCIO-Policy, 

E-Government and Fair Information 

Practices (PE&F)

Policy, E-Government and Fair Information Practices

Privacy Impact Assessment 
Privacy Impact Assessment – Guidance and Template

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Privacy Impact Assessment for the

Investigation Tracking and Enforcement Management System

(ITEMS)

May 13, 2020

Contact Point 

Shaquita Parker

USDA MRP IT 

301-851-2750

Reviewing Official 

Tonya Woods

Privacy Officer 

United States Department of Agriculture

301-851-2487
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Abstract 

IES investigates alleged violations of Federal laws and regulations related to the mission of the 

Agency. The ITEMS Tracking System is used in the management of the investigations from 

discovery through final action. ITEMS is used for preparing reports for programs within the 

Agency, other Federal agencies, OMB, and Congress upon request. ITEMS’ provides a secure 

Web-based interface to an Oracle database. 

A Privacy Impact Assessment (PIA) is being conducted because the data from the migrated 

legacy system, used as historical data for ITEMS, contains the information from the public, as 

subjects of an investigation or as witness information that could be personally identifiable.

Overview 

IES investigators conduct investigations inputting case information into the ITEMS’ system 

and retaining all supporting documentation about the case. At IES Headquarters, the branch 

chiefs assign completed investigations and non-investigated cases to appropriate Investigative 

and Compliance Specialists or Enforcement Specialists, as their respective workload allows, to 

conduct case review activities and issue penalties to alleged violators when appropriate. IES 

users also check status of a case and view case information submitted by investigators.

The ITEMS system owner and the contact information: 

Eileen Sullivan

Director

Investigative and Enforcement Services

USDA/APHIS

4700 River Road, Unit 85

Riverdale, MD 20737

(301) 851-2787

Eileen.F.Sullivan@usda.gov

Section 1.0 Characterization of the Information 

The following questions are intended to define the scope of the information requested and/or 

collected as well as reasons for its collection as part of the program, system, rule, or technology 

being developed. 

1.1 What information is collected, used, disseminated, or maintained in 

the system? 

The system uses the following Customer information:

Our customers are either subjects of an investigation, witnesses, or government officials 

referring an alleged violation to IES. The Case ID is used to refer to one or more subjects 

and/or witnesses. ITEMS system uses the following information about a subject: 
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• Subject of investigation including their address (including mailing address), telephone 

number (including work, FAX and home numbers), email address, and organization name and 

address if subject is a business, type of infraction, copies of violations reports, compliance 

agreements, warning notices, Office of General Counsel recommendations to the Department 

of Justice (DOJ), court disposition documents, complaints, consent decision documents, and 

decisions and orders. 

• Witness names including their address (including mailing address), telephone number 

(including work, FAX and home numbers), email address, and organization name and address 

if subject is a business, 

• Referring official names. Referring officials are often also witnesses.

• TIN and DUNS number for business and SSN, date of birth for individuals is not a mandatory 

field in ITEMS, however, investigators may collect this information as a way to ensure the 

enforcement of fines is assessed to the right individual. 

• Final disposition information for the cases and for cases that are issued penalty. The system 

captures penalty fees assessed, required fee payments, and uses payment amount, payment 

date and the payment transaction number. 

• Information regarding the investigation case disposition and status 

The system uses the following information about IES employees:

 Name, address (including mailing address), telephone number (including work, FAX and 

home numbers), eAuth id, email address, and organization name and job function.

1.2 What are the sources of the information in the system? 

Information in this system comes primarily from USDA employees (APHIS, AMS, and 

FSIS) or other regulatory enforcement personnel (DHS/CBP, states regulatory 

officials), and on-line data sources (LexisNexis). Investigation activities, investigation 

findings, witness statements, interviews, documents obtained from commercial 

database searches, and APHIS Program records are also sources of information used in 

the system. Information for cases generated is entered through violation referral and is 

based on the information documented in forms PPQ-518, PPQ-591 or PPQ-592 or in 

the violation referral information furnished by programs when submitting a request for 

investigation by IES. Court records are received from the US Department of 

Agriculture Office of Administrative Law Judges and any applicable state and federal 

court Records.

1.3 Why is the information being collected, used, disseminated, or 

maintained? 

The data collected is used in the investigation of alleged APHIS violations. The 

information is used to track the investigation from initiation through final determination 

to support enforcement action, as appropriate. The information is used to inform the 

alleged violator or subject of the stipulations and penalties determined by the 
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government. The system tracks payments of stipulations and penalties. The information 

is also used for referral of a case to OIG, Department of Justice or Internal Revenue 

Service (IRS), for debt collection or treasury offset.

1.4 How is the information collected? 

Information is collected through a variety of investigative techniques. Interviewing 

(subjects, co-workers, business associates, anyone perceived as having knowledge of 

the individual, company or anyone having knowledge of the potential violation), site 

visits and requests from other investigators for additional information. 

1.5 How will the information be checked for accuracy? 

The investigator checks the information for accuracy, by verifying during the verbal 

interview and/or obtaining a signed statement, when possible. The staff and 

investigators use the IES intelligence analysis unit (who have access to multiple open 

source information systems (such as Google), state records, and other supporting 

documents) to verify accuracy of information being collected, in addition to other 

sources of evidence collected during the investigation.

1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

The notification that is published in the Federal Register that explains to the public the 

authorities granted to APHIS, IES to collect this type of information in support of the 

investigative duties assigned, is detailed in the Systems of Records Notice – APHIS-1: 

(7 U.S.C. 7701–7772; 21 U.S.C. 101–105, 111–134, 7 U.S.C. 2131 et seq.; 15U.S.C. 

1821 et seq.; 31 U.S.C. 3711–3719.). The records in this system are used to issue 

invoices and collect funds due to the Government in compliance with the Debt 

Collection Act of 1982, Pub.L. 97-365, 96 Stat. 1749, as amended by Pub.L. 98-167, 97 

Stat. 1104, and the Debt Collection Improvement Act of 1996, Pub.L. 104-134, 110 

Stat. 1321; and case management information in this system is used to monitor 

compliance with the Government Performance and Results Act of 1996. 

IES directs and coordinates investigations for laws APHIS enforces:

• Plant Protection Act 

• Animal Health Protection Act 

• Virus Serum Toxin Act 

• Commercial Transportation of Equines to Slaughter Act 

• Animal Welfare Act 

• Horse Protection Act 

• Agricultural Bioterrorism Protection Act 

• Honey Bee Act 

• Federal Seed Act 
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• Lacey Act import declaration requirements

Regulatory authority is derived from Titles 7 and 9 of the Code of Federal Regulations 

(CFR) involving Animal welfare; Horse protection; Disease eradication; Interstate 

movement of livestock, plants, plant products, or plant pests; Veterinary biologics; 

APHIS’ accredited veterinarian program; Biological Toxins and Agents; Domestic 

quarantines; Endangered Species; Foreign Quarantines; Genetically Engineered 

Organisms; Hawaii Quarantines; Honey Bees; Import/Export; Noxious Weeds; Plant 

Pests; and the Seed Act. The information collected supports the investigation and 

enforcement of these regulations. 

1.7 Privacy Impact Analysis: Given the amount and type of data 

collected, discuss the privacy risks identified and how they were 

mitigated. 

SSN/TIN information is no longer a mandatory field in ITEMS, however if it is collected 

during the course of the investigation it is encrypted through Oracle Wallet Encryption 

Service (AES 192) which encrypts the SSN/TIN. All migrated data from the legacy IESTS system that may still contain SSN/TIN, is also encrypted through Oracle Wallet 

Encryption Service (AES 192) which encrypts the SSN/TIN and only eAuthenticated 

government employees with appropriate clearance are able to access it. 

Mitigation:

i) Access to the site is through https protocol which guarantee information transmitted 

through the network is encrypted

ii) Access ITEMS application is restricted through an eAuthentication

iii) SSN# / TIN is stored in an encrypted format in the database.

iv) ITEMS maintains database shadow tables to keep track of users making updates to 

critical data information

Section 2.0 Uses of the Information 

The following questions are intended to delineate clearly the use of information and the 

accuracy of the data being used. 

2.1 Describe all the uses of information. 

The principle purpose is to maintain a record of APHIS investigations. This includes

notifying the investigation subject(s) of the final disposition of their case, to track debt 

collection and to support the prosecution of cases from initiation to closure. This 

includes the possible referral of a case to OIG, Department of Justice, IRS, external 

organizations, or debt collectors. The data collected will also be used to manage and 

issue subpoenas and notifications; perform inspections, investigations, and permit-
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related activities; prepare permits, letters, and other documents; generate reports to 

evaluate quality of the case and effectiveness of the program; determine if the action 

requested in the case would additionally subject to other Federal or State authorities; 

and facilitate and account for payments.

2.2 What types of tools are used to analyze data and what type of data 

may be produced? 

Data Analysis and reporting is done through a reporting tool called IBM Cognos. IBM 

Cognos produces reports that reflect the data analysis used to assist IES in tracking the 

types of investigations, trends in violations captured. Using this tool, IES is able to

manage workload, analyze cases, and identify violation trends, and track the status of 

penalty payments.

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

The investigators use LexisNexis, LexisNexis Banko, Accurint, Accurint LE Plus, 

Treasury Enforcement Communication System, Automated Targeting System, 

Emergency Action Notification System, and other publicly available tools like Public 

Access to Electronic Records (PACER), and other internal systems that include 

ePermits, SITC National Information, Communication, and Activity System (SNICAS) 

to verify if the information collected is accurate. In addition, they use other websites 

such as Secretary of State websites, Google Maps/Google Earth, eBay, SAFERSYSUSDOT and Spokeo. 

2.4 Privacy Impact Analysis: Describe any types of controls that may be 

in place to ensure that information is handled in accordance with the 

above described uses. 

SSN and TIN#’s are stored in an encrypted form. Unauthorized users cannot extract PII 

from the database, which is stored in a secure data center at NITC. ITEMS uses a role 

based ID and Password which is eAuthenticated. The data administrator tracks and 

audits all users accessing the system. 

SSN/TIN information is no longer a mandatory field in ITEMS, however, if it is 

collected during the course of the investigation it is encrypted through Oracle Wallet. 

Encryption Service (AES 192) which encrypts the SSN/TIN. All migrated data from the 

legacy IES-TS system that may still contain SSN/TIN, is also encrypted through Oracle 

Wallet Encryption Service (AES 192) which encrypts the SSN/TIN and only 

eAuthenticated government employees with appropriate clearance are able to access it. 

Mitigation: 
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i) Access to the site is through https protocol which guarantee information transmitted 

through the network is encrypted 

ii) Access ITEMS application is restricted through an eAuthentication 

iii) SSN# / TIN is stored in an encrypted format in the database. 

iv) ITEMS contains shadow table that tracks all people who have access to ITEMS and 

any changes that are made and what changes were made to critical data information.

Section 3.0 Retention 

The following questions are intended to outline how long information will be retained after the 

initial collection. 

3.1 How long is information retained? 

Information is kept indefinitely pending NARA approval of the records retention 

schedule.

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

Information is kept indefinitely pending NARA approval of the records retention 

schedule. 

3.3 Privacy Impact Analysis: Please discuss the risks associated with the 

length of time data is retained and how those risks are mitigated. 

Records are not purged from the system because violator history can impact future 

enforcement actions. Records are kept by the program in its original format and stored. 

The system restricts level of access (read-only, update, etc.) based on roles and grants 

minimum level of privileges needed. 

Section 4.0 Internal Sharing and Disclosure 

The following questions are intended to define the scope of sharing within the United States 

Department of Agriculture.

4.1 With which internal organization(s) is the information shared, what 

information is shared and for what purpose? 

IES’ primary customers include APHIS’ Animal Care, Biotechnology Regulatory 

Services, Plant Protection and Quarantine, and Veterinary Services programs. Selected 

individuals from other APHIS program offices are allowed to access ITEMS, for the 
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purpose of following up on investigations that are specific to their program’s mission in 

supporting the enforcement of APHIS regulations. These individuals may be allowed to 

create a violation referral to initiate a case and will be allowed to query on their case 

with read-only access. If OIG needs information they request information directly from 

IES. Information is shared with NFC for receipt of violation payments. Documents and 

information stored in ITEMS may be shared with the USDA Office of the 

Administrative Law Judges and with the USDA Office of the General Counsel. IES 

investigations are used by APHIS to form the factual basis for administrative 

enforcement actions, and as such IES often refers its investigations to the USDA Office 

of the General Counsel. The USDA Office of the General Counsel provides legal advice 

to APHIS and is responsible for filing and litigating administrative enforcement actions 

on behalf of APHIS. Such administrative enforcement actions are filed with the USDA 

Office of the Administrative Law Judges. IES shares information with the USDA Office 

of the General Counsel and the USDA Office of Administrative Law Judges as 

necessary to pursue and support administrative enforcement actions. This information 

is shared through paper reports.

4.2 How is the information transmitted or disclosed? 

The information is transmitted electronically via email or database as well as through 

verbal communication between program officials and mailed in a secure package by a 

Government approved carrier. Payments are not mailed to NFC, but are sent to a lockbox (bank) located in St. Louis, MO, who in turn sends information to the APHIS 

Financial Management Division. 

4.3 Privacy Impact Analysis: Considering the extent of internal 

information sharing, discuss the privacy risks associated with the 

sharing and how they were mitigated. 

The information pertaining to investigations are only shared on a need to know basis 

with the appropriate program officials. Proper safeguards are in place and the records, 

both paper and electronic, are accessible only to authorized personnel. Multiple security 

measures are in place to prevent outsiders from entering the system. Only necessary

information is shared. On all new data, SSN/TIN is not collected and on legacy data, all 

SSN/TIN data is encrypted or obscured so that it is not visible. 

Section 5.0 External Sharing and Disclosure 

The following questions are intended to define the content, scope, and authority for information 

sharing external to USDA which includes Federal, state and local government, and the private sector. 

5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 
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Routine uses of records maintained in the system, including categories of users and the purposes 

of such uses: 

1. Referral to other Federal, State, local or foreign investigative, prosecuting, or 

enforcement agencies, when information available indicates a violation or potential 

violation of law, general statute, particular program statute, rule, regulation or order, 

whether civil, criminal or regulatory in nature. For example, APHIS works collaboratively 

with the Department of Homeland Security, Customs and Border Protection, to conduct 

inspections and pursue enforcement actions for violations of APHIS-administered statutes, 

and accordingly shares information with DHS-CBP electronically in order to facilitate 

such enforcement. APHIS also works collaboratively with state and local agencies, and 

upon request, will share information with them that may relate to a potential violation of 

law, in accordance with the parameters outlined above. 

2. Disclosure to the DOJ for use in litigation when: (a) The Agency, or any component 

thereof; or (b) any employee of the Agency or his or her official capacity where the 

Department of Justice has agreed to represent the employee; or (c) the United States 

Government, is a party to litigation or has an interest in such litigation; and by careful 

review, the Agency determines that the records are both relevant and necessary to the 

litigation and the use of such records by the DOJ is therefore deemed by the Agency to be 

for a purpose that is compatible with the purpose for which the records were collected. 

3. Disclosure to a court or adjudicative body in a proceeding when: (a) The Agency or any 

component thereof; or (b) any employee of the Agency in his or her official capacity; or 

(c) any employee of the Agency in his or her individual capacity where the Agency has 

agreed to represent the employee; or (d) the United States Government, is a party to 

litigation or has an interest in such litigation, and by careful review, the Agency 

determines that the records are both relevant and necessary to the litigation and the use of 

such records is therefore deemed by the Agency to be for a purpose that is compatible 

with the purpose for which the Agency collected the records. 

4. Disclosure may be made to a congressional office from the record of an individual in 

response to an inquiry from the congressional office made at the request of that individual. 

5. Information contained in this system of records may be disclosed to a debt collection 

agency when USDA determines such referral is appropriate for collecting the debtor's 

account as provided for in US Government contracts with collection agencies executed 

pursuant to 31 U.S.C. 3718. 

6. Where prior collection efforts have failed, the USDA will refer to the Department of the 

Treasury information from this system of records concerning past due legally enforceable 

debts for offset against tax refunds that may become due the debtors for the tax year in 

which referral is made in accordance with IRS regulations at 26 CFR 301.6402-6T, offset 

of past-due Legally Enforceable Debt Against Overpayment, and under the authority 

contained in 31 U.S.C. 3720A.

7. Information contained in this system of records may be disclosed to a consumer 

reporting agency in accordance with 31 U.S.C 3711(e). 
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5.2 Is the sharing of personally identifiable information outside the 

Department compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If so, please 

describe. If not, please describe under what legal mechanism the 

program or system is allowed to share the personally identifiable 

information outside of USDA. 

Yes. Routine uses is covered under APHIS-1. Please refer to section 5.1 for list of 

routine uses. 

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

Employees may share ITEMS information with external organizations three ways: 

electronically, verbally, or in paper format. Electronic sharing, such as through email, 

means that the transmission must follow agency email policies. For paper format, 

employees must use secure envelopes when sharing information to safeguard the 

confidentiality of data and to prohibit unauthorized access. If employees communicate 

information verbally, then standard PII (Personal Identifiable Information) protocols 

must be used, including transmission only on a need to know basis.

5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

The identified privacy risk was the further disclosure of information pertaining to point of 

contact and information of alleged violators to outside sources. To mitigate this risk, 

employees follow agency policies when they disclose or share information. These policies are 

in place to protect the data against misuses and to safeguard its confidentiality. 

Section 6.0 Notice 

The following questions are directed at notice to the individual of the scope of information collected, 

the right to consent to uses of said information, and the right to decline to provide information. 

6.1 Does this system require a SORN and if so, please provide SORN 

name and URL.

ITEMS uses the APHIS-1 SORN, 

https://www.ocio.usda.gov/sites/default/files/docs/2012/APHIS-1.txt

6.2 Was notice provided to the individual prior to collection of 

information? 
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Yes. Investigators provide oral notice to individuals prior to collecting information and a 

privacy statement is provided on the Emergency Action Notification (EAN) and on the 

affidavit signed by the individual providing the information. It also informs the individual 

about IES’ System of Records Notification published in the Federal Register, USDA/APHIS1: Investigative and Enforcement Records Regarding Regulatory Activities, USDA/APHIS

6.3 Do individuals have the opportunity and/or right to decline to provide 

information? 

Yes, individuals have both the opportunity and right to decline to provide information. 

6.4 Do individuals have the right to consent to particular uses of the 

information? If so, how does the individual exercise the right? 

Yes, individuals have the right to consent to particular use of information. They exercise 

that right by signing the affidavit which details the information collected and the reason 

for collecting it, and the privacy statement on the back of the affidavit. 

6.5 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

Notice is provided orally to individuals at the time of interview. Individuals are asked 

to sign an affidavit that contains a privacy statement, which mitigates the risk associated 

with individuals being unaware. 

Section 7.0 Access, Redress and Correction 

The following questions are directed at an individual’s ability to ensure the accuracy of the 

information collected about them. 

7.1 What are the procedures that allow individuals to gain access to their

information? 

Individuals cannot gain access to their information on the system. They are able to make 

a FOIA/Privacy Act request or to contact IES regarding their information by submitting 

a written request to: the system manager: Director, Investigative and Enforcement 

Services, USDA, APHIS, 4700 River Road, Riverdale, MD 20737-1232 also include 

PA contact information. 

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

If inaccurate or erroneous information is found it is corrected by the individual prior to 

signature on the affidavit. If the inaccurate or erroneous information is found on the 
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application, there is a provision to edit/delete incorrect data. The data can only be edited 

by the investigator of record or the system administrator of the system. If during an 

investigation inaccurate information is discovered, it can only be corrected by that 

investigator or the system administrator in edit mode. 

7.3 How are individuals notified of the procedures for correcting their 

information? 

Individuals are notified in person at the time of interview to verify and correct the 

information if needed. The individuals are notified of the Privacy Act and SORN 

information which they are required to sign. The SORN identifies the procedures for 

correcting information. Stating that any individual who believes, however, that he or 

she has been denied any right, privilege or benefit for which he or she would otherwise 

be eligible as a result of the maintenance of such material may request access to the 

material. Such requests should be addressed to the APHIS Privacy Act Officer, LPA, 

USDA, APHIS, 4700 River Road, Riverdale, MD 20737-1232 or by email at 

APHISPrivacy@usda.gov. 

7.4 If no formal redress is provided, what alternatives are available to the 

individual? 

Not applicable

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

Not applicable

Section 8.0 Technical Access and Security 

The following questions are intended to describe technical safeguards and security measures. 

8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

IES documented the user access in the ISO 9000 Certification, which defines the 

criteria, procedures, controls, and responsibilities regarding user access. User access is 

determined by the position and function of their job, supervisory, non-supervisory, 

support, etc. Program access is a read-only when requested by the program. Users are 

required to complete eAuth application online; roles are determined by the IES 

Director and access is granted by the ITEMS Administrator. 

The ITEMS System Administrator will perform quarterly and annual audits in 

compliance with the NIST Standards, AC2.1 and AU2.3. The IES-TS users were 
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grandfathered in as certified eAuthenticated users to ITEMS. An AD513 is used to 

document all user changes as of 11/01/2011, and will be audited both quarterly and 

annually. 

8.2 Will Department contractors have access to the system? 

Yes – If approved by IES and on a limited basis Contractors may be provided access 

to the system to help with troubleshooting purposes and, or verify system 

functionality.

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

All APHIS employees are required to take a mandatory IT security training every year 

which touches on PII as well as confidential and classified information. Also, all IES 

employees have clearance levels ranging from Secret to Top Secret and are trained in 

the awareness of these types of systems.

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

ITEMS has completed C&A Phase 2 and received the Authority to Operate (ATO) on

December 7, 2017. 

The ATO expires on December 7, 2020. 

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

All user actions like adding new data, modifying and/or deleting existing data is 

logged for auditing purposes, by the system administrator. The current IES-TS users 

are grandfathered in as certified eAuthenticated users to ITEMS. An AD513 is used to 

document all user changes as of 11/01/2011, and will be audited both quarterly and 

annually by the ITEMS system administrator. 

8.6 Privacy Impact Analysis: Given the sensitivity and scope of the 

information collected, as well as any information sharing conducted 

on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

IES Investigators are no longer required to collect or add PII data to ITEMS; it is not a 

mandatory field in the system. If SSN or TIN are collected, that data is encrypted or 

obscured so that it is not visible. PII data is not shared. 

Section 9.0 Technology 
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The following questions are directed at critically analyzing the selection process for any technologies 

utilized by the system, including system hardware and other technology. 

9.1 What type of project is the program or system? 

ITEMS is a Web Based information system, hosted at NITC, for tracking analyzing and 

monitoring investigation information of alleged APHIS violations from discovery 

through final judgment. 

9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

No, the technology the ITEMS system employs does not raise privacy concerns, 

because, as new individuals are identified and entered into the system, PII information 

is not required to be collected. Migrated data from the legacy system that may still 

contain PII, is encrypted and only eAuthenticated government employees with 

appropriate clearance are able to access it. PII data is not shared.

Section 10.0 Third Party Websites/Applications 

The following questions are directed at critically analyzing the privacy impact of using third 

party websites and/or applications.

10.1 Has the System Owner (SO) and/or Information Systems Security 

Program Manager (ISSPM) reviewed Office of Management and 

Budget (OMB) memorandums M-10-22 “Guidance for Online Use of 

Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”?

Yes

10.2 What is the specific purpose of the agency’s use of 3rd party websites 

and/or applications?

The ITEMS System does not use or link to third party websites, however the IES 

intelligence team uses LexisNexis and other open source websites to verify that the 

publicly known data collected is accurate. 

10.3 What personally identifiable information (PII) will become available 

through the agency’s use of 3rd party websites and/or applications.
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No PII is requested or made available through the third party website. The ITEMS 

System does not use or link to third party websites.

10.4 How will the PII that becomes available through the agency’s use of 

3

rd party websites and/or applications be used?

Not Applicable- No PII is requested or made available through the third party website. 

The ITEMS System does not use or link to third party websites

10.5 How will the PII that becomes available through the agency’s use of 

3

rd party websites and/or applications be maintained and secured?

Not Applicable- No PII is requested or made available through the third party website. 

The ITEMS System does not use or link to third party websites

10.6 Is the PII that becomes available through the agency’s use of 3rd party 

websites and/or applications purged periodically? 

Not Applicable- No PII is requested or made available through the third party website. 

The ITEMS System does not use or link to third party websites

10.7 Who will have access to PII that becomes available through the 

agency’s use of 3rd party websites and/or applications?

Not Applicable- No PII is requested or made available through the third party website. 

The ITEMS System does not use or link to third party websites

10.8 With whom will the PII that becomes available through the agency’s 

use of 3rd party websites and/or applications be shared - either 

internally or externally?

Not Applicable- No PII is requested or made available through the third party website. 

The ITEMS System does not use or link to third party websites

10.9 Will the activities involving the PII that becomes available through 

the agency’s use of 3rd party websites and/or applications require 

either the creation or modification of a system of records notice 

(SORN)?

Not Applicable- No PII is requested or made available through the third party website. The 

ITEMS System does not use or link to third party websites

10.10 Does the system use web measurement and customization technology?
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No, ITEMS does not use web measurement and customization technology.

10.11 Does the system allow users to either decline to opt-in or decide to 

opt-out of all uses of web measurement and customization 

technology?

The ITEMS system does not use web measurement and customization technology.

10.12 Privacy Impact Analysis: Given the amount and type of PII that 

becomes available through the agency’s use of 3rd party websites 

and/or applications, discuss the privacy risks identified and how they 

were mitigated. 

Not Applicable-ITEMS does not use or link to third party websites. 

Responsible Officials 

Eileen Sullivan, USDA APHIS IES

United States Department of Agriculture
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Approval Signature 

________________________________ 

Preston Griffin

Acting APHIS Information System Security Program Manager

Animal and Plant Health Inspection Service

United States Department of Agriculture

_________________________________

Tonya Woods 

APHIS Privacy Act Officer

Animal and Plant Health Inspection Service

United States Department of Agriculture

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Eileen Sullivan

System Owner – APHIS ITEMS

Animal and Plant Health Inspection Service

United States Department of Agriculture